Comment on USDA proposed Rules for Implementation of the Organic Foods Production Act

1. GENERAL:
I request that the proposed Rule now in comment period be
withdrawn, and a new Rule be prepared which better comports with
the requirements of the Organic Foods Production Act (OFPA), 7 USC
sec. 6501 et seq. , and accurately reflects the recommendations of
the National Organic Standards Board (NOSB).

I am careful in my diet to avoid manufactured, packaged, or
prepared foods. I buy Organic produce whenever possible. At the
local commercial supermarket, some produce is labeled "Certified
Organic". In the absence of further information, such as which
farm grew it, what production standards were followed, etc., I do
not purchase such items. I do buy organic produce with a label
identifying the producer and the standards applied, such as
California Organic Standards certification.

This is why I support the establishment of uniform standards for
the production of foods labeled "organic". Such standards should
define a minimum set of requirements; such minimum requirements
should define a "gold standard" of safety and purity that
distinguishes "organically prepared" foods from other edibles in a
distinctive and definitive manner, with a minimum overlap of
characteristics. Finally, producers of organic foods should be
allowed and encouraged to exceed governmentally established minimum
standards in their products, and to so label their products in a
truthful, accurate, and verifiable manner, so as to establish
market positions for premium and super-premium products, as occurs
in markets for any other commodity.

The proposed USDA rule fails in every respect to accomplish these
results. If adopted as proposed by the current Rule, it would
render the very term organic food meaningless. Industrial food
processors would be able to participate in the Organic Foods
marketplace with little change to their current practises.
Producers of industrial foods would not face meaningful competition
from the present producers of Organic Foods, who mostly provide a
premium product at a higher producer cost and a higher market
price.
Consumers would, under the labeling provisions of your
proposal, be unable to distinguish the "real thing" from
foods contaminated with municipal wastes(proposed sec
205.22, 62 Fed Reg 65892-65893) or pesticides and
antibiotic-resistant microbes, subtly altered by
radiation (sec 205.17,Fed Reg 65884), or produced in
conditions (in the case of animal husbandry) that
enlightened consumers object to because of their cruelty.
Traditional organic producers would, therefore, be unable
command a premium price for their goods, and would have
either to follow the much less costly practises of the
industrial producers, or go out of business. There would
be no economic incentive to produce foods by the
traditional methods of a genuinely organic agriculture;
such a practise would largely cease to exist.

The wolves of the processed food industry are trying to dress
themselves in sheepskins, and the USDA is assisting the process.
Therefore, I request that the Rule be withdrawn and reformulated.

2. GENERAL
In formulating the present Rule, USDA had changed the NOSB's
emphasis on process standards to performance or results standards.
(62 Federal Reg. 65869). This has allowed USDA to create large,
vague exemptions from the organic processes originally recommended
by NOSB. In addition, USDA has altered definitions (e.g., organic,
unavoidable residual environmental contamination), and added new
ones (non-active synthetic, cytotoxic mode of action), in the
attempt to change the program into one that is performance-based.
These tend to allow for new exemptions from required organic
processes as recommended by NOSB (sec 205.1, 205.2 Fed. Reg. 65865-
65867).
***********************************
SUMMARY
The present proposed Rule seeks to replace the best with the
mediocre. The term "organic food" as presently understood would
lose its meaning under the regime of the new Rule. More than just
a very high standard of food production, the term "organic" as
applied to foods connotes a political, social, and economic culture
which is beneficial to and valued by a substantial and growing
segment of the American population. Your proposed Rule is hostile
to that culture, and would degrade or destroy it.
I therefore request that you withdraw your National
Organic Program, Proposed Rule, and replace it without
undue delay (see appendix A) with a new rule which
comports with the requirements of the OFPA, 7 USC sec.
6501, et seq., and reflects the original recommendations
of the NOSB, without alteration or addition.
****************************************

APPENDIX A
I heard a few days ago in the news that the Monsanto Corporation is
asking that any decision about the allowance or prohibition of
Genetically Engineered Organisms be delayed for two - or was it
three? - years. This is unnecessary. No delay should be granted.
Regulation of Monsanto's products and processes and judgements
about their efficacy and safety can take place in an arena having
nothing to do with standards for "organic" foods. There is a
variety of Federal agencies with authority in this sort of thing.
As noted above, genetic engineering in the production of foods,
while possibly permissible in the general marketplace, has no
legitimate role in a segment of the market which must be
differentiated by exclusion of such practises.

Of related interest is an excerpt from a statement presented to the
Vermont House of Representatives in March, 1997, during hearings
about the Aerial spraying of hardwood trees (using Glyphosate, or
Roundup, the Monsanto product).

"To define "well-being" so narrowly as to exclude the
long-term economic and cultural effects of government
policies is short-sighted at best. At worst it is
incompetent. The issue of the biological effects of
Glyphosate, which Champion proposes to use, is a minor
one in this context. However, regardless of reported
test results for a compound (have you followed the
disclosures about cigarettes and the suppressed research
results from the tobacco companies during the past
months?), there have been many instances during the
twentieth century of substances and processes believed to
be safe, or reported to be safe, that ultimately resulted
in significant harm both to users and bystanders.

My position on safety is simply this: any substance
applied by spray will be ingested by people and animals,
no matter how carefully it is applied. The more often it
is applied, the more it will be ingested (breathed,
swallowed, skin penetration). The brief testing of a
compound on lab animals gives no indication of cumulative
effects, particularly food-chain concentration,
concentration in milk, and so on. And unless
conclusively proven otherwise by inductive or "bottom-
up" means, that is, long term contolled environmental
studies, any biologically active substance may be
presumed to have at least some effect on any sort of
metabolism, whether fungal or mammalian. Monsanto's
claims appear to be made on a strictly deductive basis:
since Glyphosate has a specific and known effect on a
small number of amino acids presumably present only in
the target plant species, it cannot possibly be of harm
to other organisms. Well, maybe. Then, of course,
there is the "inert" carrier. ENTRY II may be harmless
in its proposed use, but how much data do you have?

In short, there is good scientific reason to subject to
extensive further scrutiny every single statement
supporting the use of Glyphosate in the document which I
picked up at the December 12 hearing in Montpelier.

© 1998 18th Century Industries, Inc.     Please read copyright notice.

Next page: comments on USDA's rules regarding the
National List of Allowed and Prohibited Substances

Return to Organic Foods Home Page

Return to ReadOnly Table of Contents (essays on Health and Behavior)

ELWOOD TURNER: "Good Things for Kids" HOME PAGE